Accomplice (Parties to Crime)

Accomplice (Parties to Crime)

DPP for Northern Ireland v Maxwell [1978]

D was a member of a prohibited terrorist group (UVF) and, being a local man, guided other terrorists to a public house called the Crosskeys which was owned by a Catholic. A bomb was ignited, but D was NOT involved in that activity and had not, at any time, had the bomb in his possession.

His appeal was rejected. Viscount Dilhorne explaining the decision ...

 'An accessory who leaves it to his principal to choose is liable, provided always the choice is made from the range of offences from which the accessory contemplates the choice will be made.'

*Accessory (legal term), a person who assists a criminal but is not present at the crime 

**Principal (criminal law), one (or more) primary actor(s) in a criminal offense for which other actors may be criminally liable as accomplices, accessories or conspirators

Bainbridge [1960]
Six weeks before any criminal activity took place, Bainbridge used a false name and address to purchase oxygen-cutting equipment. This was later used by the principal offenders to cut through the door, windows and safe of the Midland Bank.
Bainbridge was charged as an accessory to burglary but argued he did not know the purpose for which the equipment was going to be used. He said he suspected something something illegal was going on, but that the equipment was to be used for breaking up stolen good or something similar.
C of A rejected his appeal, because they considered he had knowledge that a crime of the type in question was intended. See also DPP for Northern Ireland v Maxwell [1978]